Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision and its ramifications for taxpayers and HMRC.
The procedure by which HMRC opens an enquiry into a personal tax return closes its enquiry and if appropriate issues an assessment will be familiar to most readers.
Ordinarily HMRC will require a return to be filed under TMA 1970 s 8(1) for the purposes of establishing any amounts in which a person may be chargeable to income tax and/or capital gains tax in respect of a particular year of assessment. HMRC may then issue a notice of enquiry under TMA 1970 s 9A to a taxpayer in respect of a return; and in due course close its enquiry by issuing a closure notice under TMA 1970 s 28A. A closure notice must state HMRC’s conclusions and make any necessary amendments to the return...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
Adam Craggs and Constantine Christofi (RPC) review a recent tribunal decision and its ramifications for taxpayers and HMRC.
The procedure by which HMRC opens an enquiry into a personal tax return closes its enquiry and if appropriate issues an assessment will be familiar to most readers.
Ordinarily HMRC will require a return to be filed under TMA 1970 s 8(1) for the purposes of establishing any amounts in which a person may be chargeable to income tax and/or capital gains tax in respect of a particular year of assessment. HMRC may then issue a notice of enquiry under TMA 1970 s 9A to a taxpayer in respect of a return; and in due course close its enquiry by issuing a closure notice under TMA 1970 s 28A. A closure notice must state HMRC’s conclusions and make any necessary amendments to the return...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
